Supporters of Manston Airport’, in Conjunction with ‘History of Manston Airfield’
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Submission regarding heritage aspects on the Manston Airport site by ‘Supporters of Manston Airport’, in conjunction with ‘History of Manston Airfield’. 16th June 2019. Summary ‘History of Manston Airfield’ is a non-profit history project run to research and promote the history of aviation at Manston. It is also aimed to help promote publications about Manston and the museums. The project is not directly connected with either of the two museums currently at Manston and the submission makes no claims to speak for either of the museums currently based at Manston. This submission is based on the concerns over the retention and development of the historic features of Manston Airport. There are concerns about historic features that could be lost, or where close proximity of development may be detrimental to them. This is not intended to be a critique or opinion in regards to the current application outside of the heritage aspects of the current application which would apply to any future use of Manston airport. We are concerned that the recent hearing held 3rd June 2019 on Landscape, Design, Archaeology and Heritage spent only around 15 minutes discussing non-designated assets when there appears to be disagreement or lack of agreement between the applicant and interested parties. We were also concerned although they were in attendance in the public area, it appeared that representatives from the museums were not included in the Interested Parties invited to attend and participate in the discussions for both their own futures and those of heritage features on the site. We are aware of further discussions on 7th June 2019 and there appears to be some way to go before agreement between the applicant and interested parties. We have concerns that the applicant appears dismissive of the potential of at least some historic buildings/structures on Manston as stated by Historic England in response to Question HE.3.2 as part of the Deadline 7a Submission. It would also seem that further surveying and analysis must take place in order to document them. We agree that the loss of the buildings and features cannot be largely mitigated by recording only, but it seems that protection of all of them does not form part of the development plans, contrary to The Airports National Policy Statement (2018) (ANPS). The history of Manston is a highly emotive subject, to which the applicant and examiners will be well aware. The site has been involved with the battles of World War II on the Western Front including the Battle of Britain, Dunkirk, D-Day, Dieppe and Market Garden. It has helped to protect our country as well as the local population, Kent and London from attack in both World Wars. Countless airmen, ground crews and other workers have been lost on the site and countless others have been saved when landing back at Manston after being damaged or low on fuel. 1 We would urge the inspectors to ensure sufficient measures are in place to make sure that surveying of all archaeological and historic features, known and unknown, is carried out in full consultation with interested parties. Further we would request that all existing features from the military history of Manston are protected. We would hope these sites are preserved and form part of a wider scheme of historic protection and education for the public as suggested by the KCC submission. At this point in time, it would appear that the applicant’s plans do not include the protection of all the potential heritage on the site. We would agree with this statement by Historic England in their representation of 22nd February 2019. “There are no designated heritage assets within the proposed development site at the present time; however we think that further heritage assessment work might reveal heritage assets that have a level of importance equivalent to designated heritage assets such as listed buildings or scheduled monuments, which is one of the main reasons that Historic England has made representations about this application.” We also note and support the following statements: Deadline 3 Submission QUESTION E.1.8 - INCOMPLETE SURVEYS 1.3.1. “Enough information is available to indicate that there are certainly some important historic buildings on the airfield. It is Historic England’s view, on the basis of this information, that the T2 Hangar, WWII Dispersal Bay, RAF Manston Control Tower and the RAF Manston WWII Battle HQ are potentially nationally important and if so should be preserved. However, the relatively superficial survey on which the ES depends might prove to either underestimate or overestimate of the level of significance for each building so decisions about which buildings should be preserved may not be well-founded with the result that unjustified harm might be caused or unjustified constraints on development might be imposed. Additionally, the ES is not clear about the applicant’s proposals for which buildings would be demolished or retained, so consideration of the likely impact of the development is made doubly difficult.” It is clear that the large proportion of the proposed development already covers the original site of RNAS Manston and the subsequent grass runway and development of the site through its alteration to RAF Manston and subsequent use in WWII. Whilst understanding that the development would not proceed if it was to avoid these areas, it does show that the open aspect of the site and these areas will already be compromised, so as much concern as possible should be made in relating to the other features. We also remain concerned for the future of the two museums at Manston. Plans for their continued role at Manston appear to be unclear. Although the suggestion is that the agreements between the applicant and museums falls outside of the scope of the application, their locations are inside the area included for compulsory acquisition and they also would be in close proximity to the access road being proposed and airport development plans. 2 Manston has already lost another Museum in 2014 after being at Manston for 20 years. The Manston Fire Museum is currently at Scunthorpe after initially relocating to RAF Scampton. Protected Military Remains There appears to be a discrepancy in two of the applicant’s documents regarding military remains. In: https://infrastructure.planninginspectorate.gov.uk/wp- content/ipc/uploads/projects/TR020002/TR020002-003612- Draft%20Written%20Scheme%20of%20Investigation.pdf by Wood Environment & Infrastructure Solutions UK Limited, it suggests: 5.4.5 The 1986 Protection of Military Remains Act (PMRA) applies to any aircraft which have crashed while in military service and to certain wrecks of vessels which were wrecked while in military service. PMRA makes it an offence to disturb, move or unearth military remains which have been designated. 5.4.6 There are no designated protected areas or controlled sites within the site boundary, and there are no records of military vessels or aircraft having been lost within the site boundary. Whereas in https://infrastructure.planninginspectorate.gov.uk/wp- content/ipc/uploads/projects/TR020002/TR020002-002423-5.2-8%20- %20Environmental%20Statement%20-%20Volume%208%20-%202%20of%203%20- %20Appendix%209.1%20Part%201%20cont.pdf by Amec Foster Wheeler, it states: 4.6.33 Additionally, there are 14 potential protected military remains within the study area, 11 of which are located within the limits of the site. These assets are detailed in Table 4.4 below. Table 4.4 Protected Military Remains within the study area (original table is partly duplicated) Reference UID Name DKE20136 ME109 DKE20248 BB893 DKE21799 Crash site of Messerschmitt Bf109E-4 DKE21805 Crash site of Heinkel HE 111H-2 DKE21806 Crash site of Messerschmitt BF110D DKE21807 Crash site of Messerschmitt BF110D DKE21808 Crash site of Supermarine Spitfire I DKE21809 Crash site of Supermarine Spitfire I DKE21823 Crash site of Bristol Blenheim DKE21825 Crash site of Consolidated B24H Liberator DKE21826 Crash site of Consolidated B24J Liberator DKE21827 Crash site of Hawker Typhoon IB DKE21828 Crash site of Hawker Typhoon IB DKE21829 Crash site of Heinkel HE111H-2 3 We would seek clarification in which of the two statements are being suggested by the applicant (or which take precedent), what measures would be in place to protect any known sites and mitigation should further sites be found. Dispersal Bay The applicant has made a case to exclude features such as the T2 Hanger and WWII Dispersal bay, quoting the Historic England’s Listing Selection. However, the full quote includes the following “…group value with related structures…”, such that it does not exclude individual buildings or features. The full section quote is: “Outside these key sites, it is only groups (of buildings, fighter pens and defences) and individual examples of strong intrinsic or associational importance, particularly those with key historical episodes of the Second World War, which have been recommended for protection (Fig 8). Selection principles will include rarity; technical or structural interest; group value with related structures; and operational importance (such as direct involvement in an important campaign such as the Battle of Britain or the Battle of the Atlantic).“ https://historicengland.org.uk/images-books/publications/dlsg-military/heag123- military-structures-lsg/ The same dispersal bay can be seen on an aerial photograph of RAF Manston taken on 5th June 1942, which shows at least five bays over the entire site. It could be argued that the fact that part of the structure exists could provide opportunities for rebuilding or part-rebuilding by heritage or educational groups to illustrate their use and to be included in the wider story of the site. 4 Figure 1 – 5th June 1942 5 Figure 2 – Close up The same pens are also shown on aerial photos taken by the RAF in 1946/1947, which also shows the T2 Hanger.